UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 

## DEC .2 02013

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION MEMORANDUM
SUBJECT:

FROM:

THRU: BEAD Responses to the Comments on the Simazine BEAD Chemical Profile (080807) (EPA-HQ-OPP-2013-0251-0005) and Preliminary Work Plan (EPAHQ-OPP-2013-0251-0008)
Bill Phillips, PhD, Agronomist

## ~ Biological Analysis Branch

### ,)'?'~' Jihad Alsadek, PhD, Economist

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# ~ Science Information and Analysis Branch Stephen Smearman, Economist Economic Analysis Branch Biological and Economic Analysis Division (7503P) AmetJones, Chief /]

# ~**~** Biological Analysis

# Br**· ~**  Diann Sims, Chief Science Information and Analysis Branch Timothy Kiely, Chief 

# rl\._**~** Economic Analysis Branch

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# J \A..A._ Biological and Economic Analysis Division 03P) TO: Molly Clayton, Chemical Review Manager Risk Management and Implementation Branch 3 Pesticide Re-evaluation Division (7508P)


### Product Review Panel date: December 17,2013 The Environmental Protection Agency (Agency) is implementing the registration review program pursuantto Section 3(g) ofthe Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and will review each registered pesticide every 15 years to determine whether it continues to meet the FIFRA standard for registration. Changes in science, public policy, and 1pesticide use practices occur overtime. The registration reviewprogram is intended to make sure that, as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard. The public phase ofregistration review begins whenthe initial docket is opened for each case. Information onthis program is provided onthe Agency's website. (EPA 2012) Registration review may consist ofa review ofavailable information on a pesticide, risk assessments, and, potentially, risk management. The Biologic and Economic Analysis Division's (BEAD) role is to provide relevant use and usage information for risk assessments and to conduct benefit/impact assessments to inform risk management. In the case of agricultural uses, these impacts could include changes in yield, in the quality ofproduce, and/or the cost ofproducing the commodity that affect producers' income and, potentially, could affect consumers through the supply and price ofcommodities. OnJune 26, 2013 the federal docket (HQ-OPP-2013-0251) for the registration review ofthe active ingredient simazine was opened to the public to receive comments regarding the preliminary work plan and supporting science documents. The 60 day public comment period ended on August 26, 2013. This comment periodprovided the public the opportunity to submit comments about the work that had been undertaken up to the June docket opening. The Environmental Protection Agency received comments from various groups and individuals. Syngenta Crop Protection, LLC provided the only comments focused on the BEAD chemical profile document (EPA-HQ-OPP-2013-0251-0005). Below BEAD has provided responses to the comments that were submitted to the simazine docket. EPA thanks the public for comments provided to the simazine docket during the public comment period. Information provided to the docket and any additional information submitted by the public regarding the agronomic, weed science and/or economic relevance ofatrazine could be useful in future alternatives and/or benefits analysis.

I. Comments and Responses on the BEAD ChemicalProfile for Registration Review: Simazine (080807) (EPA-HQ-OPP-2013-0251-0005)
Comment 1. EPA Statement Page 2, Herbicide Discussion, "
..Simazine can be used postemergence to the weed
...." Syngenta Comment: Syngenta respectfully requests to delete "post-emergence" from the sentence. BEAD Response: In the BEAD chemical profile it states that "Simazine can be used postemergence to the weedas afoliar appliedherbicide, however since it is readily absorbed 2through the rootsystem, it isprimarily appliedas apre-plant incorporatedorsoilapplied herbicide. The characterization ofsimazine applicationtiming was incorrect in that applications that are made postemergence should be made postemergence to the crop, after the crop has emerged, but before there are weeds present.

Comment2. EPA Statement Page 3, Common Formulations and Application Methods "
..Simazine is formulated either as a liquid, emulsifiable concentrate...." Syngenta Comment: Syngentarespectfully requests to delete emulsifiable concentrate as a type offormulation. BEAD Response: We agree that Syngenta simazine products are not formulated as emulsifiable concentrates. Other registrants have simazine products that are formulated as emulsifiable concentrates.

II. Comments and Responses on the Simazine PreliminaryWorkPlan (EPA-HQ-OPP2013-0251-0008)
Comment 1. EPA Statement Page 5, Table 3. Summary ofUse "
..Simazine can be applied postemergence to the weed
...." Syngenta Comment: Syngenta respectfully requests to delete "post-emergence" from the sentence. BEAD Response: Refer to BEAD's response in Section I, Comment I.
Comment2. EPA Statement Page 6, Table 3, Use Sites "
...Registered for use on crops including
...Brussels sprouts, cranberry, persimmon,"

3Syngenta Comment: Syngenta does not support use on cranberry, please (sic) delete from the list. Persimmon is also not supported, as the Special Local Needs label (SLN) has been cancelled. BEAD Response: BEAD agrees thatthere are no Simazine registrations supporting use on persimmons. However, while there are no Syngentaregistrations that support use oncranberries, there are several registrations that do support this use (e.g., 19713-273, 19713-60, 72693-7).

Comment3. EPA Statement Page 3, Table 3, Formulation Types(s) "
..Simazine is formulated either as a liquid, emulsifiable concentrate...." Syngenta Comment: Syngenta respectfully requests to delete emulsifiable concentrate as a type offormulation. BEAD Response: Refer to BEAD's response in Section I, Comment 2.

References: EPA 2012, Pesticides: Registration Review. Internet Publication: http://www.epa.gov /oppsrrd1/registration _review/



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